The Department of Energy (“DOE”), Office of Electricity, recently issued a Request for Information (“RFI”), seeking comments regarding cost-effective ways to make oil and natural gas infrastructure systems more resilient against severe weather events primarily, as well as cyber and physical threats.

Relevant infrastructures include oil and natural gas companies, pipeline operators, fuel distribution and delivery firms, and other owners and operators of oil and natural gas infrastructure.

In an effort to gather “‘relevant consensus-based codes, specifications, and standards,’ and other pertinent materials to provide guidance for enhancing the physical and operational resilience of these systems and their components against such events,” DOE is seeking information including:

  • Specific technical design standards or requirements for physical system components;
  • Relevant corporate business practices, like designating a senior corporate officer responsible for the development, implementation, and ongoing maintenance of an oil and natural gas company’s resilience strategy; and
  • Analytic methods and tools for estimating the possible economic benefits from strategies, investments, or initiatives to enhance the resilience of oil and natural gas facilities

DOE is aware of safety and reliability standards which have already been developed by the oil and natural gas industries and promulgated by the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration. Submission of more detailed information about these standards is unnecessary.

Because there is presently no settled body of expert knowledge about requirements and practices for enhancing the resilience of oil and natural gas infrastructure systems, DOE hopes that gathering this information will:

  • Enable it to synthesize a body of existing expert knowledge about how best to cost effectively enhance weather-related grid resilience and make this information broadly available to interested stakeholders including policy officials
  • Assist the Federal Emergency Management Agency (“FEMA”) in its implementation of the Disaster Recovery Reform Act of 2018
  • Identify important information gaps that need to be addressed through:
    • Targeted research and development activities
    • Emergency preparedness actions by government agencies and the private sector

Comments are due August 23, 2019 and should be submitted electronically, to oilandgas.resilience@hp.doe.gov, with “Guidance for Enhancing Oil and Natural Gas Resilience” in the subject line. Commentators are cautioned not to include any document or information that might be considered commercially or business sensitive, proprietary, confidential, critical electric infrastructure information, or classified for reasons of national security. Additional details regarding this RFI and requirements for submitting comments can be found here.

Analogous resilience information pertinent to the electric sector can be found here.